BRCGS Management Review: What Senior Leadership Must Own

BRCGS requires senior management to own food safety — not delegate it. What the standard demands, what auditors check, and how to run a management review that actually works.

Food safety certification fails at the top — not on the production floor.

That is the central premise of Clause 1 of the BRCGS Global Standard Food Safety Issue 9, and it is one of the most misunderstood sections of the entire standard. Many sites treat it as a documentation exercise: get the policy signed, schedule the management review, produce the minutes, file them. Audit passed.

Auditors are not fooled. They interview senior managers directly. They check whether objectives were discussed quarterly or just rubber-stamped. They look for evidence that leadership is genuinely engaged — not just present on paper.

This guide explains what Clause 1 actually demands, how auditors assess Management Accountability, what "resource commitment" means in concrete, budget-level terms, and how to run a management review meeting that drives real improvement rather than producing a compliance artefact.

Why BRCGS Puts Management at the Top — Clause 1.1: Senior Management Commitment

The Philosophy Behind Clause 1

BRCGS Issue 9 designates Clause 1.1 as Fundamental — one of only twelve requirements in the entire standard to carry this designation. A major non-conformity against a Fundamental requirement can prevent certification from being granted. This is not a technicality. It reflects a deeply held position: that food safety cannot be owned by the quality department alone.

Culture is the operative word. And culture is set from the top. BRCGS Issue 9 is unambiguous that product safety must be led by senior management and felt throughout the organisation. Without this, consistent application of the standard across purchasing, production, maintenance, HR, and personnel cannot be reliably achieved.

Why It Cannot Be Siloed in the QA Department

Here is the operational reality: BRCGS requirements touch almost every function in a food manufacturing site.

• Purchasing is responsible for supplier approval and raw material authenticity (Clause 3.5)
• Engineering and Maintenance must support the HACCP plan through equipment integrity (Clause 4.6)
• HR and Personnel manage training, hygiene, and medical screening (Clause 7)
• Production Management owns GMP compliance and process control (Clause 6)
• Finance determines whether capital expenditure for food safety improvements is approved

No single QA Manager can compel budget decisions from Finance, enforce hygiene standards from HR, or require production managers to halt a line for a food safety concern — without executive authority behind them.

BRCGS recognises this reality explicitly. The standard's guidance notes that only where the most senior management are committed to the processes can this level of involvement be achieved consistently. Leadership behaviours, management practices, and what gets prioritised in board conversations directly influence the food safety culture on the factory floor.

What Auditors Are Actually Looking For

When an auditor walks into the opening meeting, the most senior production or operations manager on site must be present. This is a requirement, not a courtesy. Auditors will:

• Ask the site manager direct questions about food safety objectives and culture plans
• Interview workers informally to assess awareness of food safety expectations
• Check whether food safety appears as a standing agenda item in management meeting minutes
• Assess whether documented culture plans are actively implemented, not just filed
• Examine whether resource allocation decisions (staffing, capex, training budgets) reflect genuine commitment

The auditor is not looking for perfect answers. They are looking for authentic engagement. A site manager who can speak fluently to their food safety objectives and culture improvement activities demonstrates a different level of commitment than one who says "you'll need to ask the technical manager about that."

What "Resource Commitment" Means in Practice — Clause 1.1.7

The Standard's Requirement

Clause 1.1.7 is direct:

This is not a soft statement of intent. It is an enforceable requirement. The auditor will look at the type and number of non-conformities identified during the audit and assess whether inadequate resourcing is a root cause. If your site repeatedly fails on temperature monitoring, allergen labelling, or hygiene controls, and those failures trace back to understaffing, undertrained personnel, or deferred maintenance, a resource non-conformity is a legitimate audit finding.

Concrete Examples of What Resource Commitment Looks Like

Budget Allocation

• Capital expenditure approvals for food safety-critical equipment (temperature monitoring systems, CCTV in high-risk zones, allergen separation infrastructure)
• Budget lines for third-party testing, external audits, and certification body fees
• Funding for prerequisite programme upgrades identified through internal audits or non-conformity trending
• Allocation for product safety culture activities (surveys, communication programmes, recognition initiatives)

Staffing

• Sufficient technical and QA personnel to maintain the food safety management system without chronic overload
• Deputisation structures: Clause 1.2.1 requires that every responsible person has a documented deputy. Senior management must ensure those deputies exist and are trained
• A clearly documented organisational chart showing food safety responsibilities at every management level

Time and Training

• Dedicated time for internal auditors to conduct thorough audits — not squeezed into production schedules
• Access to external training for technical staff on legislative updates, emerging risks, and standard revisions
• Time carved out in the senior management calendar for the annual management review and the monthly management meetings required by Clause 1.1.5

The Auditor's Test

The auditor will assess resource adequacy both during the documentation audit and during the facility inspection. They are asking a simple question at every turn: Does this site have what it needs to run a credible food safety system?

A site where the QA Manager is also the internal auditor, the HACCP coordinator, the supplier approval manager, and the training coordinator — with no support — is a resource non-conformity waiting to be written up. Senior leadership needs to understand that resourcing decisions made in budget meetings have direct audit consequences.

The Management Review Meeting — Required Inputs and Outputs

Clause 1.1.4: What the Standard Requires

The management review meeting must occur at planned intervals, at least annually, and must be attended by the site's senior management — those with authority to make decisions on food safety objectives and the provision of human and financial resources. This typically includes the site manager and managers responsible for production, technical, purchasing, engineering, and HR.

The meeting is not a routine production meeting with a food safety item appended to the agenda. It is a full and detailed examination of the food safety management system — past performance, current status, and future direction.

Management Review: Required Inputs vs. Required Outputs

What Auditors Check in the Meeting Records

The auditor will read the management review minutes carefully. They are not looking for perfect grammar — they are looking for evidence that a real discussion happened and that decisions were made.

Good management review minutes contain:

• A clear record of what was presented for each agenda item
• Evidence of discussion (not just "noted")
• Specific, named, time-bound actions for every concern raised
• Evidence that actions from the previous review were closed out or formally carried forward
• A visible link between the meeting outcomes and the updated food safety objectives

Poor management review minutes — which regularly generate non-conformities — look like this:

• One-line entries per agenda item ("complaints reviewed — no action required")
• No record of who said what or what was decided
• Actions with no owner and no deadline
• Objectives that are identical to those set the year before, with no discussion of whether they were met
• No evidence the culture plan was discussed at all

Meeting Frequency: Annual Minimum Is Not Always Sufficient

The standard requires an annual management review as a minimum. However, Clause 1.1.5 separately requires a monthly management meeting programme in which food safety, authenticity, legality, and quality issues can be raised with senior management.

Many sites find it most practical to run:

• A comprehensive annual management review covering all Clause 1.1.4 agenda items in full
• Quarterly reviews of food safety KPIs and objectives (required by Clause 1.1.3)
• Monthly management meetings where food safety is a standing agenda item

This layered approach means emerging issues are not sitting unresolved for eleven months between annual reviews. It also generates a richer body of meeting records for the auditor to review — demonstrating active, ongoing senior management engagement with food safety, not a once-a-year compliance exercise.

Food Safety Objectives — Setting Them, Monitoring Them, and Communicating Them

Clause 1.1.3: The Requirements

Senior management must define and document clear objectives to maintain and improve:

• Product safety
• Product authenticity
• Product legality
• Product quality

These objectives must be documented with measurable targets, communicated to all staff, and reviewed with results reported to senior management and all staff at least quarterly.

The auditor will look for documented evidence of quarterly communication. A QA Manager who reviews objectives quarterly in a meeting with no minutes, no communication cascade, and no evidence of staff awareness will not satisfy this requirement.

What Makes a Good Food Safety Objective

Use the SMART framework. BRCGS expects objectives that are:

• Specific — "Reduce customer complaints" is a direction. "Reduce foreign body complaints by 20% by Q4" is an objective.
• Measurable — There must be a baseline and a defined metric. Percentage reductions, absolute figures, and time-bound milestones all work.
• Achievable — Stretch targets are acceptable; unachievable targets are not. Senior management must ensure that sufficient resources will be available to hit the target.
• Relevant — Objectives must connect to product safety, authenticity, legality, or quality — not generic business performance metrics.
• Time-bound — A deadline enables meaningful quarterly review and prevents objectives from drifting indefinitely.

Examples of Appropriate Objectives

• Achieve zero critical or major non-conformities in this year's BRCGS certification audit
• Reduce total customer complaints by 15% year-on-year by December [year]
• Complete allergen management procedure review and revalidation by Q2
• Achieve 100% on-time completion of internal audit programme for the calendar year
• Reduce out-of-specification finished product incidents by 25% by year-end
• Complete food safety culture plan activities for Q1 and Q2 by June

The Quarterly Communication Requirement

This is a common source of non-conformities. Senior management must demonstrate that objective progress was reviewed and communicated at least four times during the year. Methods include:

• Team briefings or toolbox talks with documented attendance
• Noticeboard displays updated quarterly with progress figures
• Monthly management meeting minutes recording KPI performance
• Electronic communication (email, intranet) with evidence of distribution

Simply reviewing the numbers in a management meeting without cascading the results to the workforce does not satisfy Clause 1.1.3.

The Food Safety and Quality Culture Plan — More Than a Policy Statement

Clause 1.1.2: What Is Required

Senior management must define and maintain a documented plan for the development and continual improvement of food safety and quality culture. This plan must include:

• Defined activities involving all sections of the site that impact product safety
• Clear and open communication on product safety
• Training activities
• Feedback mechanisms from employees
• Defined behaviours required to maintain and improve product safety processes
• Performance measurement of product safety-related activities
• An action plan with timescales and named owners
• A review of the effectiveness of completed activities

The plan must be reviewed and updated at least annually.

What a Culture Plan Is Not

A food safety policy signed by the managing director is not a culture plan. A mission statement on the canteen wall is not a culture plan. A training matrix is not a culture plan, though it may form one component of it.

A culture plan is a living, implemented programme that demonstrates how the organisation is actively working to shift the attitudes, behaviours, and values of its people regarding food safety.

BRCGS is explicit on this point: Culture is not simply a matter of introducing another policy, but on developing attitudes and a positive approach to product safety.

Common Culture Plan Activities That Satisfy the Requirement

• Staff surveys assessing food safety awareness and reporting confidence, with results reviewed and acted upon
• Employee recognition programmes for food safety improvement suggestions
• Regular two-way communication channels between the production floor and senior management on food safety topics
• Root cause investigation programmes that involve front-line staff, building ownership of corrective actions
• Training beyond procedural compliance — developing understanding of why food safety controls matter
• Open-door policies or structured mechanisms for staff to raise food safety concerns without fear of reprisal (noting this overlaps with the whistleblowing requirement at Clause 1.1.6)

Non-Conformity Risk: What Gets Sites into Trouble

A major non-conformity is raised where no documented culture plan exists. The interpretation guideline is clear: a short statement of intent does not qualify. The plan must address all required elements.

A minor non-conformity is raised where a plan exists but:

• Lacks detail (no timescales, no named owners, no action plans)
• Does not cover all relevant areas or staff categories
• Is not fully implemented — activities planned but not completed

Note that the review of effectiveness element is not assessed at the first audit under the standard. From the second audit onwards, the auditor will expect to see documented evidence that completed activities were evaluated and the plan updated accordingly.

The Confidential Reporting System — Clause 1.1.6

This clause is often underestimated. Senior management must ensure there is a genuinely confidential mechanism for staff to report concerns about product safety, authenticity, legality, or quality — without fear of identification.

Key requirements:

• The reporting mechanism must be truly anonymous — an email to a site manager or a verbal report to a supervisor does not qualify
• The mechanism must be clearly communicated to all staff, including agency and temporary workers
• Senior management must have a documented process for assessing concerns raised
• Records of assessments and actions taken must be maintained

Independent or third-party systems (external ethics hotlines, professional whistleblowing services) are considered best practice, particularly for larger sites. The BRCGS "Tell BRCGS" facility does not substitute for a site-level system.

This requirement is assessed during the audit through documentation review, staff interviews, and evidence of operational functionality of the system.

Staying Current — Clause 1.1.8: Technical and Legislative Intelligence

Senior management must maintain a system to ensure the site remains informed of:

• Scientific and technical developments relevant to food safety
• Industry codes of practice
• New risks to the authenticity of raw materials
• All relevant legislation in countries where products are sold

This is not a passive requirement. The auditor will ask how the site systematically stays current. A response of "we read the BRCGS website sometimes" will not satisfy the requirement.

Credible compliance mechanisms include:

• Membership of a relevant trade association that provides legislative and technical update services
• Subscription to a legislative monitoring service (many exist across different markets and product categories)
• Regular engagement with local enforcement authorities or government food safety agencies
• A documented schedule for reviewing identified regulatory websites and updating the legislative register
• A process for translating new legislative or technical requirements into procedure updates, with evidence of implementation

What Senior Leadership Must Do Before the Next Audit

The following checklist summarises the minimum actions required of senior management to demonstrate authentic BRCGS management commitment:

Policy and Culture

• Food safety policy is current, signed by the most senior site manager, and demonstrably communicated to all staff including temporary and agency workers
• A documented food safety and quality culture plan is in place, actively implemented, and reviewed at least annually

Objectives

• SMART food safety objectives are documented and communicated to all staff
• Evidence of quarterly review and reporting of objective progress exists — not just in management meeting minutes, but cascaded to the workforce

Management Review

• The annual management review is calendared in advance, attended by all relevant senior managers, and covers all Clause 1.1.4 agenda items
• Minutes reflect genuine discussion, not agenda completion
• All actions are assigned to a named owner with a deadline, and followed up

Monthly Meetings

• Food safety, authenticity, legality, and quality are standing agenda items in monthly management meetings
• Minutes are maintained and available for auditor review

Resources

• Staffing levels, training budgets, and capital expenditure allocations demonstrably support the food safety system
• Deputisation is documented for all key food safety roles

Reporting and Intelligence

• A truly confidential staff reporting system is operational and communicated
• A system for monitoring legislative and technical developments is documented and active

Previous Non-conformities

• All non-conformities from the previous certification audit have been closed with root cause analysis, corrective action, and preventive action — and evidence of implementation is on file

The Bottom Line for Senior Leadership

BRCGS certification is not a quality department project. It is a whole-site commitment that requires executive authority, executive accountability, and executive engagement.

The standard's Fundamental designation for Clause 1.1 is not bureaucratic labelling — it reflects decades of audit evidence showing that the quality of a site's food safety system rises or falls with the quality of its leadership. Culture, resourcing, and strategic direction all flow from the top.

An auditor can distinguish a site whose senior management genuinely owns food safety from one where a QA Manager has constructed a paper system to pass an audit. The distinction shows in the meeting minutes, in the objective-setting conversations, in whether the site manager can speak to the culture plan without consulting the technical file, and in whether the workers on the floor understand what the company's food safety objectives are and why they matter.

Senior management commitment is not a clause to be managed. It is a standard to be led.

*Written with reference to the BRCGS Global Standard Food Safety Issue 9 and its official Interpretation Guideline (August 2022). All clause references are to Issue 9 of the standard.*